[Openstreetmap] EU location rights

Mike Liebhold mnl at well.com
Thu Sep 22 16:57:12 BST 2005


Hello Openmappers

According to the  EU [ see -entire- thread  below]  it is possible that 
users' -may- have rights to their own location coordinates, at no charge 
from wireless network operators. Although the regulations cited below 
are slightly equivocal it appears, at a minimum, that network operators 
are restricted from selling location coordinates -for profit- and may be 
required, under national laws to provide the data free of charge.

I may be involved in an upcoming project to help develop spatial 
information infrastructure across Africa, so a European precedent is 
quite important there too.

I'd b very grateful if someone would forward this note to WSFII and 
related lists. Thanks

Cheers-

Mike Liebhold
- a friend of the family-

(I wish I could join you all at the WSFII)



Michael Liebhold wrote:

> Dear Philippe,
>
> I recieved your message this time. I am very grateful for your help in 
> clarifying this question.
>
> Quite a few potential community services across Europe will be 
> affected by the final determination of Individuals' rights to access 
> their own location coordinates at no cost. I shall convey your 
> responses to colleagues working on a variety of services, who are 
> meeting in London, shortly  for a planning meeting.
>
> Many Thanks,
>
> Michael Liebhold
> Senior Researcher
> Institute for the Future
>
>>         -----Original Message-----
>>         *From:* GERARD Philippe (INFSO)
>>         *Sent:* Tuesday, September 13, 2005 5:16 PM
>>         *To:* 'Michael Liebhold '
>>         *Cc:* BANABLE Stephen (INFSO)
>>         *Subject:* RE: Location Rights
>>
>>         Dear Mr Liebhold,
>>          
>>         I received your request only recently. Here is a first reply
>>         on an informal basis.
>>          
>>         Article 6 and 9 of the ePrivacy Directive 2002/58/EC (see
>>         link  in Ruprecht's email, below) concern traffic and
>>         location data. Some location data may in fact be traffic data
>>         since they are needed for the transmission of the
>>         communication and may have to be used for billing or
>>         interconnection payments.
>>          
>>         Location data other than traffic data may be further
>>         processed for value added services provided the user or
>>         subscriber consents to this. Prior to that, he will have to
>>         be informed see the text of Article 9.
>>          
>>         When it comes to the rights of the user/subscriber to access
>>         their own data, the conditions are set in the general data
>>         protection rules (see Article 12 of Directive 95/46/EC, at:
>>         http://europa.eu.int/comm/justice_home/fsj/privacy/law/index_en.htm).
>>         It should be possible 'without excessive delay or expense'.
>>         There is no further hamronisation I am afraid, so that
>>         national law has to be checked to find out what exact price
>>         or expenses have to be paid if any.
>>          
>>         I hope that this is helpful. Please come bacl to me if you
>>         have further questions.
>>          
>>         My best regards,
>>          
>>
>>         Philippe GERARD
>>
>>         European Commission // Commission européenne/
>>         DG Information Society and Media // DG Société de
>>         l'Information et Médias/
>>         Directorate B - Electronic Communications Policy // Politique
>>         des Communications électroniques/
>>         Unit B1 - Policy Development // Unité B1 - Conception des
>>         politiques/
>>
>>         Tel: +32.2.296 86 44
>>         Fax: +32.2.296 17 27
>>         email: Philippe.GERARD at cec.eu.int
>>
>>             -----Original Message-----
>>             *From:* BANABLE Stephen (INFSO)
>>             *Sent:* Thursday, September 08, 2005 4:52 PM
>>             *To:* 'Michael Liebhold '
>>             *Cc:* GERARD Philippe (INFSO); PATYK Magdalena (INFSO)
>>             *Subject:* FW: Location Rights
>>
>>             Dear Mr. Liebhold,
>>              
>>             I apologise for the delay in coming back to you on your
>>             second question below. I have Asked Mr. Phillippe
>>             Gerard who is responsible for these issues to contact you
>>             directly.
>>              
>>             Regards
>>              
>>             Stephen Banable
>>
>>                 -----Original Message-----
>>                 *From:* SCHREER Valerie (INFSO)
>>                 *Sent:* Thursday, July 28, 2005 10:12 AM
>>                 *To:* BANABLE Stephen (INFSO)
>>                 *Cc:* GRECO Frank (INFSO); DE RYCK Evelyne (INFSO)
>>                 *Subject:* FW: Location Rights
>>
>>                 28/07/2005 - A/233916
>>                  
>>                 Dear Mr Banable,
>>                  
>>                 Mr Niepold received the hereunder question while
>>                 being on holidays.  As Mr Greco suggests this is more
>>                 under your competence, would you be so kind as to
>>                 answer Mr Liebhold's question.
>>                  
>>                 Thank you very much and kind regards,
>>
>>                 Valérie SCHREER MARTIN
>>                 _______________________________________
>>                 Secretary to Mr R. Niepold
>>                 DG Infso B4
>>                 Radio Spectrum Policy
>>                 Tel. 68643 - Fax 68395
>>                 ________________________________________
>>
>>                  
>>
>>                     -----Original Message-----
>>                     *From:* Michael Liebhold [mailto:mliebhold at iftf.org]
>>                     *Sent:* Wednesday, July 27, 2005 7:42 PM
>>                     *To:* NIEPOLD Ruprecht (INFSO)
>>                     *Subject:* Re: Location Rights
>>
>>                     Hello Ruprecht,
>>
>>                     Thanks for your prompt and helpful reply. I'm
>>                     sorry I missed the first message while
>>                     travelling.  Do you and your colleagues
>>                     understand to these rules to mean that operators
>>                     may -profit- providing location coordinates to
>>                     users or whether they are obliged to provide
>>                     location on a -cost recovery- basis? And if cost
>>                     recovery is specified,  what burden may passed to
>>                     users if capture of locations is mandatory for
>>                     network operators?  Or, are these subleties that
>>                     will be resolved later on?
>>
>>                     Many thanks again,
>>
>>                     Michael
>>
>>
>>
>>
>>                     Ruprecht.Niepold at cec.eu.int wrote:
>>
>>>                     27/7/05
>>>                      
>>>                     Dear Michael,
>>>                      
>>>                     thanks for your message. I fact, I sent you an
>>>                     e-mail on 30 June 2005, see below, but it
>>>                     obviously did not reach you.
>>>                      
>>>                     I hope that my indications respond to your
>>>                     questions.
>>>                      
>>>                     *** Ruprecht Niepold
>>>
>>>                     Head of Unit
>>>                     DG INFSO B4: Radio Spectrum Policy
>>>                     Office: BU33 7/5
>>>                     Address: 200, Rue de la Loi, B-1049 Bruxelles ,
>>>                     Belgium
>>>                     Tel: +32 2 29 68955
>>>                     Fax: +32 2 2968395
>>>                     e-mail: Ruprecht.Niepold at cec.eu.int
>>>                     <mailto:Ruprecht.Niepold at cec.eu.int>
>>>
>>>                      
>>>                      
>>>                     ___________________
>>>                      
>>>
>>>                     30/6/05
>>>
>>>                     Dear Mr. Liebhold,
>>>
>>>                     It was nice to exchange with you en marge of the
>>>                     Telecoms Transition Conference in Lisbon and to
>>>                     learn about geospatial web.
>>>
>>>                     You asked me a question on the situation in
>>>                     Europe concerning location data held by
>>>                     operators. Here are some clarifications:
>>>
>>>                     - from the privacy point of view: I confirm that
>>>                     an operator must not use location data without
>>>                     consent of the mobile user (except for limited
>>>                     cases such as emergency etc.). This is enshrined
>>>                     in the European Privacy and Electronic
>>>                     Communication Directive, see details under:
>>>                     _http://europa.eu.int/information_society/topics/ecomm/all_about/todays_framework/privacy_protection/index_en.htm_
>>>
>>>                     - My colleague expert in this piece on
>>>                     legislation told me further (on the basis of an
>>>                     explanation, not a formal legal interpretation
>>>                     of the texts applicable): On request, an
>>>                     operator must indicate to a mobile user what
>>>                     personal data he holds. Therefore, if solicited,
>>>                     the operator would have to notify the user that
>>>                     he holds location data. The mobile user can then
>>>                     claim to have access to these data, however the
>>>                     operator would be entitled to charge for this if
>>>                     he wished to do so.
>>>
>>>                     Hope this clarifies the situation
>>>
>>>                     *** Ruprecht Niepold
>>>
>>>                         -----Original Message-----
>>>                         *From:* Michael Liebhold
>>>                         [mailto:mliebhold at iftf.org]
>>>                         *Sent:* Wednesday, July 27, 2005 7:43 AM
>>>                         *To:* NIEPOLD Ruprecht (INFSO)
>>>                         *Subject:* Location Rights
>>>
>>>                         Ruprecht Niepold
>>>                         Head of Unit
>>>                         Radio Spectrum Policy
>>>                         European Commission
>>>                         Information Society and Media Directorate
>>>                         General
>>>
>>>                         Hello Ruprecht,
>>>
>>>                         We met briefly at the Telcoms conference in
>>>                         Lisbon a few weeks ago. I'm the researcher
>>>                         from the Institute for the Future working
>>>                         on  grass roots location services and the
>>>                         geospatial web.
>>>
>>>                         In passing, I thought I heard you mention
>>>                         that perhaps mobile network operators may
>>>                         not be legally entitled to sell, or use
>>>                         themselves, a user's location coordinates
>>>                         for commercial service offerings, without a
>>>                         users explicit permission. Also, you may
>>>                         recall, that I asked you if carriers are
>>>                         able to determine users coordinates, then do
>>>                         users have a legal right to know their own
>>>                         location coordinates?
>>>
>>>                         When I asked, You said that you would
>>>                         clarify this when you returned to your
>>>                         office. I would be very grateful if you
>>>                         could help shed some light on this issue. 
>>>                         This is a fundamental platform component for
>>>                         a great number of potentially innovative and
>>>                         useful applications.
>>>
>>>                         Many Thanks, in advance, for your kind
>>>                         assistance.
>>>
>>>                         Michael Liebhold
>>>                         Senior Researcher, Geospatial Web
>>>                         The Institute for the Future
>>>

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